Trustees of David Zetland Settlement v HMRC [2013] UKFTT 284 (TC)

The First-tier Tax Tribunal has denied inheritance tax business property relief on a block of office lettings owned and managed by a trust.  The main reason given was that a commercial letting is mainly an investment rather than a business even though many of the services provided were over and above what would normally be expected under a tenancy. 

The decision shows how difficult it is to persuade a tribunal that let property is not mainly the holding of an investment.  

The report from the First-tier Tax Tribunal can be found here.